Travel & Export Compliance Guidance

Often, the devices we carry when we travel are for our convenience.  Most of these devices have some form of encryption technology and in many cases, there is no problem in traveling with such devices. But, for some countries, you may need an export license or export license exception. Other countries, such as Pakistan, India, and China, have severely regulated or banned encryption technology.  

TIP:  If all you need your laptop for is to check email, take a “clean” device or use the hotel’s business center. Loaner cellphones may be an option to consider. 

All university-owned laptops that are issued with the standard image include encryption software. This software is export-controlled and therefore travel to an embargoed/restricted country (see USDOC Country Group D-5 or Country Group E –pages 6, 7, 8 U.S. Arms Embargoed Countries List) will require the traveler to obtain authorization from the U.S. Government well in advance of travel.  In this situation, contact the Director, Export Control Compliance. 

If you are traveling for personal reasons (e.g., family emergency, vacation, etc.) and you have intentions to ‘work’ – depending on your destination, you may not be able to perform business activities without obtaining U.S. Government authorization in advance. This restriction primarily affects travel to embargoed countries, especially with travel to Iran. This includes logging into the UM network from your personal device or any other connection while in the restricted country. Please consult with the Director, Export Control Compliance well in advance of your anticipated departure date. 

Taking technical data and other documentation that may be considered controlled, proprietary or restricted is another element of your travel plans that needs to be reviewed. If you do not absolutely, positively need it with you – do not take it. If you feel you must, make sure it is not your only copy.  

If the information you are carrying on your device is not publicly available, then it warrants protection. It is highly recommended that you do not put such information in online storage services (i.e. Cloud Computing) as these are not completely secure resources for protecting your data. If you are unsure whether such information is sensitive, review the terms of your agreement or award. Any information disclosed should be “publicly available” unless the persons are approved as “need to know." 

Have you checked to make sure that the individual(s) and/or entity(ies), that you are meeting with, or any vessel that you may be using, do not appear on a denied/restricted party list? 

As a representative of one of the United States top-tier universities, you are at risk of being a victim to espionage activity – and you may not even be aware when it is happening. You may even consider your position at the University to be insignificant and thus not making you vulnerable. Unfortunately, you do not need to be in a prominent position or highly sought-after field of research to be targeted. You may have heard the expression, “It’s not what you know, but who you know that matters." This is very true in the world of espionage. 

Do any of the individuals and/or entities you are collaborating with appear on any denied or restricted party list? It does not matter whether they are   being compensated or not, scholar or student – all individuals should be checked. This is applicable to organizations that have asked you to come present at a conference or other forum. If you are contracting with a vessel that will be used in foreign or international waters, it too should be screened. 

• I am an Iranian national and will be traveling to my home country for personal reasons.  Is it okay that I check my UM email account and conduct University business while I am home? 
• Unfortunately, this type of activity may not be done without a license from the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) in place well in advance of your travel.  This restriction is also true for any University personnel regardless of their nationality. Please consult with the Director, Export Control Compliance prior to traveling. 
• Can I take my laptop, tablet or smartphone to Haiti? 
• Yes, but because these devices have encryption technology embedded into them, you will need to obtain from the Director, Export Control Compliance authorization under U.S. Department of Commerce’s License Exception TMP (Temporary) or BAG (Baggage). If the device is owned by UM, you will need License Exception TMP; if it is personally owned by you, you will need License Exception BAG.  The SOP for this subject can be viewed on Export Control Compliance Policies & Forms page under the heading "Travel." Please consult with the Director, Export Control Compliance well in advance of your travel. 

For additional guidance, feel free to contact the Director, Export Control Compliance at exportcontrol@med.miami.edu and 305-284-9558 

Have a safe trip!